Doe No. 59 v. Santa Rosa City Schools

Filing 60

ORDER granting 59 STIPULATION to Continue Fact and Expert Discovery Cutoff Dates. Close of Fact Discovery continued to 4/24/2017. Expert Discovery deadlines continued 14 days. Signed by Judge William H. Orrick on 04/10/2017. (jmdS, COURT STAFF) (Filed on 4/10/2017)

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1 2 3 4 5 6 Eugene B. Elliot, State Bar No. 111475 Ethan M. Lowry, State Bar No. 278831 Kate L. Brown, State Bar No. 308134 BERTRAND, FOX, ELLIOT, OSMAN & WENZEL The Waterfront Building 2749 Hyde Street San Francisco, California 94109 Telephone: (415) 353-0999 Facsimile: (415) 353-0990 Email: eelliot@bfesf.com 7 8 Attorneys for Defendant SANTA ROSA CITY SCHOOL DISTRICT 9 10 UNITED STATES DISTRICT COURT 11 12 JANE DOE NO. 59, NORTHERN DISTRICT OF CALIFORNIA Case No. 3:16-cv-01256-WHO 13 Plaintiff, 14 15 16 v. SANTA ROSA CITY SCHOOLS, Defendants. 17 18 STIPULATION AND ORDER TO CONTINUE FACT AND EXPERT DISCOVERY CUTOFF AND RELATED CROSS-ACTION. Hon. William H. Orrick 19 20 STIPULATION Defendant SANTA ROSA CITY SCHOOLS (the “DISTRICT”) and plaintiff JANE DOE NO. 59 21 22 by and through their respective attorneys of record, hereby stipulate as follows: 23 1. The Court originally assigned a Fact Discovery cutoff date of February 14, 2017. The 24 Parties requested additional time to complete discovery on February 13, 2017. The Court granted the 25 parties proposed stipulated Fact Discovery cutoff date of April 10, 2017. 26 27 28 30 31 2. Both parties require additional time to complete discovery. Trial is set for August 14, 3. The DISTRICT intends to conduct the following further discovery: (1) depose the officers 1 2017. STIPULATION AND ORDER TO CONTINUE FACT AND EXPERT DISCOVERY CUTOFF USDC Case No.: 3:16-cv-01256-WHO 1 involved in the incident. DOE intends to conduct the following further discovery: (1) depose 2 Defendant’s District Representative(s) in accordance with Rule 30(b)(6), and (2) depose Lindsey 3 Apkarian. 4 4. The parties therefore respectfully request that the Court extend the Fact Discovery cutoff 5 date 14 days to April 24, 2017. This extension will not affect the trial date or any other dates previously 6 set by the Court. The parties’ stipulation of extending the Fact Discovery cutoff is contingent on such an 7 extension not affecting the trial date. 8 5. Further, Defendant’s expert is unable to provide a written report until April 28, 2017. The 9 parties respectfully request that the Court extend the Expert Discovery deadlines 14 days as follows: (1) 10 Expert Disclosure: April 28, 2017. This extension will not affect the trial date or any other dates 11 previously set by the Court. 12 contingent on such an extension not affecting the trial date. 13 10. 14 In fact, the parties’ stipulation of extending the Discovery cutoff is The parties respectfully request that the Court approve this stipulation and incorporate its terms in an Order. 15 16 Dated: April 10, 2017 17 BERTRAND, FOX, ELLIOT, OSMAN & WENZEL By: 18 19 20 /s/ Ethan Lowry Eugene B. Elliot Ethan M. Lowry Kate L. Brown Attorneys for Defendant SANTA ROSA CITY SCHOOL DISTRICT 21 22 Dated: April 10, 2017 HERMAN LAW 23 By: 24 25 /s/ Arick Fudali Arick Fudali, Esq. (Calf. Bar No. 296364) Daniel G. Ellis, Esq. (Calf. Bar No. 298639) Attorneys for Plaintiff JANE DOE NO. 59 26 27 28 30 31 2 STIPULATION AND ORDER TO CONTINUE FACT AND EXPERT DISCOVERY CUTOFF USDC Case No.: 3:16-cv-01256-WHO 1 ATTORNEY ATTESTATION 2 I hereby attest that I have on file all holograph signatures for any signatures indicated by a 3 conformed signature (“/s/”) within this E-filed document or have been authorized by all parties to show 4 their signature on this document as /s/. 5 6 Dated: April 10, 2017 By: /s/ Ethan Lowry Ethan M. Lowry 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 30 31 3 STIPULATION AND ORDER TO CONTINUE FACT AND EXPERT DISCOVERY CUTOFF USDC Case No.: 3:16-cv-01256-WHO 1 ORDER 2 GOOD CAUSE APPEARING THEREFORE, and the parties’ having stipulated to the same, the 3 parties’ stipulation is hereby APPROVED. The Fact Discovery cutoff currently set for April 10, 2017 is 4 continued 14 days to April 24, 2017. This extension will not alter or affect the trial date or any other 5 dates previously set by the Court. 6 7 Expert Discovery deadlines are continued 14 days as follows: (1) Expert Disclosure: April 28, 2017. This extension will not affect the trial date or any other dates previously set by the Court. 8 9 IT IS SO ORDERED. 10 11 12 Dated: April 10, 2017 William H. Orrick UNITED STATES DISTRICT JUDGE 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 30 31 4 STIPULATION AND ORDER TO CONTINUE FACT AND EXPERT DISCOVERY CUTOFF USDC Case No.: 3:16-cv-01256-WHO

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